On 9 May 2023, the Treasurer announced in the 2023–24 Budget that the Australian Government will implement the Organisation for Economic Cooperation and Development (OECD) Global Anti-Base Erosion (GloBE) Model Rules (also known as global minimum tax) and a domestic minimum tax. The 15% global minimum tax and 15% domestic minimum tax will apply to large multinationals with annual global revenue of EUR750 million (approximately $1.2 billion) or more.
This measure is not yet law and new legislation will be introduced.
In scope multinational groups will need to:
- provide new information to adhere to the reporting obligations under the global minimum tax and domestic minimum tax (this may require new systems)
- lodge a GloBE Information Return (GIR)
- the GIR will need to be lodged 18 months after the first year end (15 months for subsequent years)
- the OECD have published the GIR, for details download GloBE Information Return (PDF, 1.3MB).
To deliver on the intent of the OECD GloBE rules and a domestic minimum tax, of interest to this group, the following key elements need to be delivered:
- New electronic approved forms complying with the OECD’s specified XML schema and new Australian tax returns complying with domestic requirements for an approved form to enable assessment and collection of Top-up Tax
- Lodgment and compliance processes designed to be in pattern with existing systems
- An international data exchange component to share relevant information with implementing tax administrations
- IT systems to capture and store lodged and exchanged data for reporting and administration purposes.
- New data and analytics capabilities to process and analyse the stored information, as well as exchange capabilities where required.
See our website for more information on the implementation of the GloBE rules and domestic minimum tax.
Key dates:
The start dates for the:
- 15% global minimum tax for large multinational enterprises will occur over two years with the
- Income Inclusion Rule to apply to years starting on or after 1 January 2024, and
- Undertaxed Profits Rule to apply to years starting on or after 1 January 2025.
- 15% Domestic Minimum Tax to apply to years starting on or after 1 January 2024.
Consultation:
Australia’s adoption of the Implementation of a global minimum tax and a domestic minimum tax - working group
The purpose of this working group is to co-design and discuss technical considerations for implementation of the measure, ensuring alignment with the ATO’s requirements and standards as well as providing a good user experience.
The working group will discuss and review:
- Options for appropriate channel selection to support new obligations
- Interoperability with other tax jurisdictions, as this is a global requirement
- Potential risks and challenges in the software development process and provide opportunities to develop strategies to mitigate them
- Record keeping requirements for the measure
- Lodgment obligations for early balancers (Substituted Accounting Periods).
The ATO consultation framework underpins our consultation framework arrangements.
For a list of current members, see Australia’s adoption of the implementation of global minimum and domestic minimum tax working group members (PDF, 36KB).